ABC Life Co can rely on Top Insurance Brokers Ltd, an insurance intermediary, to carry out which of the following Customer Due Diligence requirements on behalf of the life company? (i) Identifying a customer. (ii) Verifying the identity of the beneficial owner of a customer. (iii) Obtaining information on the purpose of the business relationship with a customer.

• A. (i) only.
• B. (ii) and iii) only.
• C. (i) and (ii) only.
• D. (i), (ii) and (iii).

Answer: (D)

The key idea is that a life company can rely on an intermediary to perform CDD tasks on its behalf, as long as the intermediary is regulated and the life company maintains oversight. The three items listed are all standard elements of customer due diligence: identifying who the customer is, verifying who ultimately owns or controls the customer (the beneficial owner), and obtaining information about the purpose and intended nature of the business relationship. If Top Insurance Brokers Ltd is empowered and regulated to collect these details, ABC Life Co can rely on them to fulfill these CDD steps, while ABC Life Co remains responsible for ensuring the information is accurate, verified, and kept up to date and for the ongoing monitoring of the relationship. Therefore, all three elements can be handled by the intermediary.